Whistleblower Policy
This Whistleblower Policy creates a process for internal disclosure of misconduct and other matters that should be disclosed to maintain good commercial practice and legal and ethical behaviour within your company. It also protects those who disclose such conduct from reprisals from those affected by such disclosures, and outlines how disclosures will be handled.
5.0 (2 reviews)
Last updated February 27, 2025
Under 5 minutes
Suitable for Australia
Written by
Edwin Montoya Zorrilla
Reviewed by
Damin Murdock
Document Overview
This Whistleblower Policy creates a process for internal disclosure of misconduct and other matters that should be disclosed to maintain good commercial practice and legal and ethical behaviour within your Company. It also protects those who disclose such conduct from reprisals from those affected by such disclosures, and outlines how disclosures will be handled. Under Part 9.4AAA of the Corporations Act 2001 (Cth), certain companies are required to have whistleblower policies that meet certain requirements. This policy meets those requirements. The companies required to have whistleblower policies include:
- Public companies.
- Proprietary companies that are the trustee of a registerable superannuation entity.
- Proprietary companies with a consolidated revenue of more than $50 million, consolidated gross assets of more than $25 million, or more than 100 employees.
The Legal Risk Score of a Whistleblower Policy Template
Our legal team have marked this document as low risk considering:
- There is a potential risk that disclosures made without sufficient evidence or based on incorrect information could expose the whistleblower to disciplinary actions, even if the intent was not malicious.
- The scope of what constitutes reportable conduct is broad, which might lead to confusion or misuse of the policy, potentially resulting in unwarranted allegations or investigations.
Users familiar with compliance documents might find this document useful but should be aware of the need for possibly further detailed procedural development to ensure consistent application and effectiveness.
Whistleblower Policy Checklist
Complete your free Whistleblower Policy with our checklist
Review and Update the Policy Regularly
Ensure that the policy is reviewed and updated as necessary to remain compliant with evolving laws and best practices.
Training and Awareness
Conduct regular training sessions to ensure all employees and stakeholders are aware of the policy and understand their responsibilities under it.
Monitor and Audit Compliance
Implement monitoring and auditing mechanisms to ensure the policy is being followed and to identify any areas of non-compliance.
Use this Whistleblower Policy if:
- You want to lay out your company's position in regards to commercial and corporate misconduct and the important of addressing it;
- You want employees to feel confident that they can report misconduct without fear of reprisals;
- You want to ensure that your company complies with the whistleblower protection provisions in the Corporations Act 2001 (Cth); and
- You want to minimise the company's liability for the misconduct of its employees.
What does this Whistleblower Policy cover?
- The types of conduct that may be reported under this policy;
- How that conduct may be reported;
- How reports will be handled so that misconduct is investigated and whistleblowers are protected; and
- The consequences for bringing negative consequences upon those who report misconduct.
Further information:
It's never been so easy
Sign-up to a free Lawpath account
Get started and we’ll take care of you. It’s that easy.
Collaborate with e-Sign and Sharing
Having access to your legal documents has never been easier. You can request e-signature, share the document and download for an efficient collaboration.
Create unlimited legal documents and eSignatures for only $39/month.
Upgrade to a Lawpath legal plan to boost your new business.
Here's what people say about Lawpath’s Whistleblower Policy
Reviews are managed by BazaarVoice and comply with the BazaarVoice Authenticity Policy. Reviews are independently verified by BazaarVoice and detail our customers' real experiences.